We prepared this Privacy Policy to demonstrate our commitment to privacy and to disclose our practices in collecting, using, and disclosing individuals’ personally identifiable information (“personal information” or “PI”). In this Privacy Policy, we use the terms “personally identifiable information”, “personal information”, and “PI” for ease of reference and out of an abundance of caution to describe information collected on this website, regardless of whether or not this information is protected under applicable privacy law. This Privacy Policy applies to the website https://thomas-and-company.com, which is owned and operated by Thomas and Thorngren, Inc. d/b/a Thomas & Company (“we”, “us”, or “our”).  Please note that a different Privacy Policy applies to our website https://verify.thomas-and-company.com and our other websites and services described in that Privacy Policy; that privacy policy can be found at https://verify.thomas-and-company.com/site/privacy/; that Privacy Policy describes, among other things, additional PI collected by us in connection with that website and our related services and our policies relating to that data’s disposition.

1. Collection, Use, and Disclosure of Personal Information.

We receive information from you submitted through the “Contact” form on our website.

• Server Log Files. To administer our website and analyze trends in the aggregate, our servers automatically collect log information when someone visits our website. This information may include the website from which you visited our site, your webpage request, internet protocol (“IP”) address, browser language, browser type, the date and time of your request, your registration data, data related to the specific function you are performing on the site, and one or more cookies that may identify your internet browser.
• Cookies and Similar Technologies. To analyze trends, administer our website, track users’ movements around the website, and gather information about our user base as a whole, we and our service providers use cookies (e.g., session) and similar technologies. You can control the use of cookies at the individual browser level, but, if you choose to disable cookies, it may limit your use of certain features or functions on our website or our services. We use a third-party solution to provide analytics regarding traffic on the site from IP addresses or similar identifiers from users’ browsers and devices.
• Access by Third Parties Assisting Us. We endeavor to ensure that third parties who may help with our business activities and to whom we disclose any of your information are aware of our privacy policy and will handle that information similarly. These companies are authorized to use your personal information only as necessary to provide these services to us consistent with our contracts with them. In such cases, these companies must abide by security requirements, and are not allowed to use personal information they receive from us for any other purpose.

2. Legal.

In certain situations, we may disclose personal information or other information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information or other information as required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmental authority request.

3. Corporate Transactions.

If we are involved in a merger, acquisition, or other fundamental corporate transaction, your information could be transferred in connection with that transaction. In such an event, we will encourage the continuing treatment of your personal information in accordance with this Privacy Policy.

4. “Do Not Track.”

Currently, we do not respond to browser “do not track” signals.

5. Security.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and while in our possession. Still, no system can be guaranteed 100% secure. If you have questions about the security of your personal information, or if you have reason to believe that the personal information we hold about you is no longer secure, please contact us immediately as described at the end of this Privacy Policy.

6. Marketing Preference / Unsubscribe.

If you provide your name and email address, we may use that information to send periodic emails to you both promotional and transactional in nature. You may choose to stop receiving promotional emails by following the unsubscribe instructions included in these emails, or you can contact us as described in this Privacy Policy.

7. Children’s Online Privacy Protection.

Our services are not structured to attract children. Accordingly, we do not solicit or knowingly collect any personal information from anyone we know to be under 16 years of age. If we are made aware that information is or has been submitted by or collected from a child younger than 16, we will immediately delete their personal information.

8. Inquiries or Requests to Review or Change Information.

You have certain rights with respect to your personal information.

You may have the right to request the categories of personal information we have collected about you; the categories of sources from which that personal information is collected; the personal information collected; the categories of personal information we have disclosed about you for a business purpose; the business purpose for collecting or disclosing the information; and/or the categories of third parties with whom we share the information.

If at any time you want to make such a request, or if you have questions or concerns about this policy, or want to change or delete any of your information that you have a right to change or delete, you may contact us via the contact information listed below. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation for the action we take.

9. Verifiable Consumer Requests; Authorized Agents.

When you seek to exercise your rights under this Privacy Policy and applicable law, we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or to have it fulfilled. In order to exercise those rights, we may require you to provide, at a minimum, first name, last name, and address. For requests submitted by mail, you will need to send copies of two forms of identification that include your first name, last name, and current address.  You may designate an authorized agent to make a verifiable consumer request on your behalf by mailing two forms of identification showing your first name, last name, and current address and a signed authorization allowing an agent to request information on your behalf.

10. Amending Our Privacy Policy.

We may amend our Privacy Policy from time to time. We will post any such changes on this website and, thereafter, will endeavor to abide by our policy as amended. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

11. California Residents.

• Pursuant to the California Consumer Privacy Act (“CCPA”), California residents may have the following rights:
• Access. The right to request that a business provide them the following information: the categories and specific pieces of personal information about them it collects, uses, discloses, and sells; the categories of sources of the personal information collected about them; the business or commercial purposes for collecting or selling their personal information; the categories of third parties to whom it sold their personal information; and the categories of third parties to whom it disclosed their personal information for a business purpose. This information, other than the specific pieces of personal information we have collected about a given individual, is provided in this Privacy Policy.
• Non-discrimination. The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA. For example, we will not deny anyone services or provide them a lower level of service in response to their exercise of any rights they have under the CCPA.
• The CCPA generally gives a California resident the right to demand that a business delete any personal information that the business has collected from the consumer, unless an exception applies.  Those exceptions include, for example, when the business needs to maintain the information to complete the transaction for which the information was requested or to provide a service that the consumer requested; to use the information internally in ways reasonably aligned with the consumer’s expectations given the context in which the consumer provided the information; or to comply with a legal obligation.  We believe our uses of personal information are for those excepted reasons.
• Opt out. The CCPA generally gives a California resident the right to demand that a business not sell any personal information collected from that consumer, absent certain exceptions.
• To the extent any information collected via the https://thomas-and-company.com website is considered personal information under the CCPA, we believe that the limited uses we make of this information, however, are largely, if not entirely, exempt from the CCPA under Section 1798.145, particularly where the information collected is deidentified or aggregate consumer information.

If a California resident believes she/he has a basis to submit a request to us under the CCPA, please submit the request through the contact information below, and we will consider it and respond.

Contact Us.

If you have a question or comment about this Privacy Policy or wish to submit a request under the CCPA or other applicable privacy law, please contact us by mail, email, or telephone, as follows:

Thomas & Company
One Vantage Way, Suite A-105
P.O. Box 280100

Nashville, TN 37228
E: [email protected]
P: (800) 310-8546

Policy Effective Date:  May 10, 2021